Underground Injection Control

Since the mid-1980s, Cadmus has worked with government and industry in their efforts to safely:

Dispose of more than 750 billion gallons of hazardous and non-hazardous waste a year by injecting it underground
Use underground injection techniques to enhance the recovery of oil and natural gas
Inject liquid hydrocarbons underground for storage

Today, we also help the U.S. EPA explore the use of underground injection to keep carbon dioxide, an important greenhouse gas, out of the atmosphere. To achieve our clients’ goals, our hydrologists, policy analysts, and communication specialists work on numerous projects concerning all types of injection wells, from deep “Class I” wells to shallow “Class V,” including:

Risk assessments of hazardous and non-hazardous waste injection
The implementation of federal requirements to manage large-capacity cesspools and systems to dispose of motor vehicle waste
Studies of risk and best management practices (BMPs) associated with the deep or shallow injection of residuals left over from drinking water treatment
Fact sheets and Web pages to help owners of Class V wells comply with state and federal regulations
Evaluations of BMPs for large-capacity septic systems
Studies of ways to efficiently manage Class V wells, including innovative approaches such as the Environmental Results Program
Development of a national underground injection control database and personal digital assistant-compatible databases of injection well locations for well inspectors

Project Example: Geologic Sequestration of Carbon Dioxide

As global temperatures rise due to increasing carbon dioxide (CO2) levels, it is important to identify and implement ways to reduce CO2 emissions to the atmosphere while allowing continued economic growth. The enormous amount of needed CO2 reductions requires a portfolio of actions. One promising option is geologic sequestration (GS), the process of injecting CO2 captured from an emission source (e.g., a power plant) into deep subsurface rock formations for long-term storage.

While decades of experience with injection technologies under the Underground Injection Control (UIC) program provide a strong basis for injecting CO2 for GS, this unique application brings about technical and administrative challenges which EPA, with support from Cadmus, is addressing in advance of commercial-scale implementation of GS.

The Challenge

On October 11, 2007, EPA’s Administrator announced that the Agency would propose regulations to address CO2 injection for GS by the summer of 2008. An accelerated rulemaking schedule was needed to allow the Agency to keep pace with the anticipated rapid development and implementation of GS. The UIC program turned to Cadmus to support an ambitious effort to prepare a proposed rulemaking package in nine months.

Our Approach

Cadmus provided EPA with technical, economic, and regulatory support as it prepared the proposed GS regulation. In a multifaceted effort in support of the Office of Ground Water and Drinking Water and the Office of Air and Radiation, Cadmus developed technical papers and economic analyses of the proposed regulation, evaluated options for and the implications of a GS regulation, and supported the Agency workgroup that developed the proposed rule.

Our Successes

Cadmus’ activities helped EPA meet its ambitious rulemaking schedule, and EPA’s Administrator signed the proposed GS regulation on July 15, 2008. Cadmus’ work also helped EPA significantly increase the knowledge base on GS including an evaluation of the safety and applicability of GS-related technologies.

Cadmus supported the rulemaking effort by evaluating technical options for managing CO2 injection for GS and assessing the economic and risk impacts of the proposed regulation. Cadmus developed a white paper on regulatory options, researched relevant technologies and their implications for GS, analyzed the costs to injection well operators and states associated with the complying with the proposed rule, and supported the Agency workgroup that wrote the proposed rule.
Cadmus developed several technical background papers to support Agency decisions about technical standards for GS wells. These papers addressed mechanical integrity and construction issues for CO2 GS injection wells, the potential for hazardous impurities in captured CO2, industry analogs for GS including CO2 injection for enhanced oil recovery and acid gas injection, and options for GS in depleted oil fields.
Cadmus helped organize and facilitate a series of technical workshops on the geological suitability of GS sites, injection well construction standards, and monitoring at GS sites during and after CO2 injection. Cadmus invited experts from around the world to present, discuss, and answer questions on current GS research. This expertise was critical to the development of the rule and the technical specifications that EPA described in the proposed GS rule.
Cadmus helped EPA develop UIC Program Guidance #83, “Using the Class V Experimental Technology Well Classification for Pilot Geologic Sequestration Projects.” This Guidance, which presents geological and engineering considerations for permitting pilot-scale GS projects, will support testing of GS technologies in a manner that protects the environment.

Cadmus will continue to support EPA as it responds to public comments on the proposed regulation, continues to research GS technologies, and issues a final regulation on GS of CO2.